WASHINGTON (9/30/08)—The Credit Union National Association (CUNA) believes the Federal Reserve Board should move ahead with its updates that would increase fees that may be charged by a financial institution for costs incurred in producing consumer financial records in response to government requests. The Fed’s proposal would amend its Regulation S, which implements Right to Privacy Act provisions. The changes are intended to modernize the fee structure by reflecting increased cost in producing records, as well as changes in the technology used. The changes include a new “per electronic production” charge of $5, instead of the previous “per diskette” charge, that will cover the cost of all electronic media or email transmissions. In its comment letter to the Fed, CUNA said that the Fed proposal meets its goals. CUNA advised, however, that the Fed not pursue its idea to eliminate current fees for microfiche duplications. These fees should not be eliminated at this time as we believe there are credit unions that still retrieve and produce records in this manner. We anticipate that this method of producing records will eventually end for all financial institutions over time, but we do not believe this will occur in the near future. The Fed proposal also would implement a mechanism to update all the reimbursement rates periodically, based on changes in the Bureau of Labor and Statistics (BLS) survey data. CUNA supports the periodic updates, but recommends that each position description in the proposal add the term “or equivalent” as this should eliminate the requirement to amend these rules if the BLS changes these position names and descriptions in the future. To view CUNA complete comments, use the resource link below.